| Current Rules, Proposed Revisions, and Projected Net Cost Differencesa | Effect of the Proposed Revision |
| USDA/Federal Government | State/Local Agencies | Vendors/Industry | WIC Participants |
Current rule: State agencies have the option to prescribe breastfed infants up to 104 fl oz of infant formula (not more than one can of powdered infant formula) during the first 30 days of life, on a case-by-case basis. Proposed revision: Breastfed infants can be prescribed up to 364 fl oz of infant formula during the first 30 days of life, on a case-by-case basis after a breastfeeding assessment by a competent professional authority, and remain categorically classified as a partially breastfed infant. (Net cost effect: savings)
| The cost of food package I-BF/FF-A itself may slightly increase, depending on how frequently competent professional authorities identify need for issuance of formula beyond 104 fl oz. The anticipated shift in fully formula fed dyads toward the partial (mostly) breastfeeding food packages is expected to largely offset additional costs of the infant formula. | At the staff and clinic level, the proposed revision is expected to provide greater flexibility in tailoring the partially (mostly) breastfed infant's food package and create opportunities to support partial breastfeeding in dyads who would otherwise be considered fully formula-fed. Management Information Systems will need to be updated. State and local agencies will encounter a short-term burden of retraining staff. | The effect on vendors or industry is anticipated to be minimal. The anticipated shift in fully formula-fed dyads to the partial (mostly) breastfeeding food packages may slightly reduce the amount of infant formula purchased by WIC participants with their food benefit. | The revision is intended to prevent women and infants from being categorized as postpartum (nonbreastfeeding or minimally breastfeeding) and fully formula fed, respectively, in the first month or soon thereafter. The proposed revision is intended to provide security for women who may try to breastfeed in the immediate postpartum period but are not yet certain they can succeed. |
Current rule: The maximum monthly allowance of formula should not be used as the standard for issuance unless the mother is not breastfeeding the infant at all. Proposed revision: The quantity of infant formula prescribed to infants should be tailored based on needs. All maximum monthly allowances for infant formula should be considered “up to” amounts. (Net cost effect: minimal)
| The cost effect of the proposed revision will depend on the extent to which infant formula tailoring occurs. If minimal tailoring occurs, the cost effects would be minimal. If it is fully executed, the proposed revision would result in a cost savings. | At the staff and clinic level, the proposed revision is expected to provide greater flexibility in tailoring the amount of formula provided to infants. Management Information Systems will need to be updated. State and local agencies will encounter a short-term burden of retraining staff. | The effect on the vendors will depend on the amount of infant formula tailoring that occurs. If minimal tailoring occurs, the effect on infant formula sales would be minimal. Full execution is likely to result in a decrease of infant formula sales to WIC participants using their food benefit. | Participants would still have access to the quantities of infant formula currently being offered by WIC. The proposed revision, however, would help participants receive the amount of infant formula needed to meet their infants' needs. |
Current rule: All food package II recipients are prescribed 24 oz of infant cereal per month Proposed revision: Food package II-BF recipients are prescribed 16 oz of infant cereal per month; II-FF and II-BF/FF recipients are prescribed 8 oz per month (Net cost effect: savings)
| The proposed revision would reduce the cost of food package II. This reduction helps offset costs elsewhere in the food packages. | Administrative burden is expected to be minimal. State agencies currently authorize 8 oz infant cereal containers; some state agencies also authorize 16 oz containers. Management Information Systems will need to be updated. State and local agencies will encounter a short-term burden of retraining staff and communicating the change to participants when the revisions are initially implemented. | The proposed revision may result in reduced infant cereal sales to WIC participants. It is not anticipated to affect stocking requirements. | Although infants will receive less infant cereal under the revised food package, the amount provided is more consistent with current complementary feeding recommendations. |
Current rule: Food package II-BF recipients are prescribed 256 oz of jarred infant food vegetables and fruits per month. All other food package II recipients receive 128 oz of jarred infant food vegetables and fruits. Up to 16 oz of jarred infant food fruits can be substituted with fresh bananas, 1 banana per 4 oz jar. Proposed revision: All infants receiving food package II are prescribed 128 oz of jarred infant food vegetables and fruits. A CVV can be prescribed for partial substitution ($10 for 64 oz jarred infant food vegetables and fruits) or complete substitution ($20 for the 128 oz). The CVV can be used to purchased vegetables and fruits in all forms authorized by the state agency (i.e., fresh, frozen, canned) except dried. (Net cost effect: increase)
| Despite the decrease in jarred infant vegetable and fruit issuance to fully breastfed infants, the option for CVV substitution are expected to lead to an increase in redemption, thereby increasing costs to the program. | Administrative burden is expected to be minimal. Management Information Systems will need to be updated, but overall it will improve Management Information Systems efficiency by authorizing the same vegetable and fruit varieties for all CVVs. State and local agencies will encounter a short-term burden of retraining staff and communicating the change to participants when the revisions are initially implemented. State and local agencies will also face an administrative burden developing educational messages and materials related to selecting and preparing vegetables and fruits appropriate for complementary feeding. | The proposed revision may result in slight reductions in jarred infant food vegetable and fruit sales to WIC participants, but it may increase fresh, frozen, and/or canned vegetables and fruits via the CVV. This is not anticipated to affect stocking requirements. | The proposed revision is intended to provide fully breastfed infants with a supplemental quantity of infant food vegetables and fruits, in the absence of definitive guidance on recommended intake. The CVV substitution option provides participants the opportunity to prepare their own infant food vegetables and fruits, which can be used to better meet diverse cultural needs, personal preferences, and the infant's developmental stage. Participants may be able to buy more servings of vegetables or fruit using the CVV compared to the jarred varieties. |
Current rule: Food package II-BF recipients are prescribed 77.5 oz of infant food meat per month. Proposed revision: Food package II-BF recipients are prescribed 40 oz of infant food meat per month. Ten oz of canned fish can be substituted for 4 jars (10 oz) of infant food meat per month. (Net cost effect: savings)
| Because redemption of infant food meat is low, reducing the amount prescribed is expected to result in slight cost savings. The option for substitution of canned fish may slightly increase redemption in this category. Given that canned fish is currently less expensive per oz than jarred infant food meat, increase in redemption may be offset by the slightly lower price. | Implementation of the proposed revision will require training WIC staff and participants of the change and new substitution option. Management Information Systems will need to be updated. | The revision may reduce the amount of infant food meat purchased by WIC participants. The substitution option may slightly increase the amount of canned fish purchased by WIC participants. | The proposed revision addresses participants' feedback about the quantity and preference in the infant food meat category, while still providing key nutrients to fully breastfed infants. The substitution option provides participants with greater flexibility in this food category. |
Current rule: Food package III is reserved for participants who have one or more qualifying conditions that require an exempt infant formula or WIC-eligible nutritional (formerly WIC-eligible medical food) to supplement their nutrition needs, as determined by the participant's health care professional. Proposed revision: Participants with a qualifying condition in which a WIC formula is not medically necessary are still eligible to receive appropriate supplementary foods through food package III. (Net cost effect: minimal)
| Clarifies that WIC formula is not an absolute requirement of food package III. The cost effects of the proposed revision will be minimal, as the number of applicable participants is expected to be extremely small. | Administrative burden increases in the short term. Management Information Systems will need to be updated. | No impact. | Some participants receiving food package III may be prescribed a package that is more appropriate for their needs. |
Current rule: Children are prescribed 128 fl oz of juice per month; pregnant, partially (mostly) breastfeeding, and fully breastfeeding women are prescribed 144 fl oz of juice per month; postpartum and partially (minimally) breastfeeding women are prescribed 96 fl oz of juice per month. Proposed revision: Children, pregnant women, partially (mostly) breastfeeding women, and fully breastfeeding women are prescribed 64 fl oz of juice per month. Recipients may opt to substitute a $3 CVV for the 64 fl oz of juice. Postpartum and partially (minimally) breastfeeding women no longer receive juice. (Net cost effect: savings)
| The reduction in juice prescribed would reduce the costs of the food packages. This reduction helps offset costs elsewhere in the food packages. | Implementation of the proposed revision will require training WIC staff and participants of the change and new substitution option. Management Information Systems will need to be updated. | Less juice would be purchased with the WIC food benefits. The minimum stocking requirements for juice would be simplified, as all participants prescribed juice would receive 64 fl oz (or frozen equivalent). | The proposed revision provides a supplemental amount of juice, which can help participants meet their daily fruit intake goals. The CVV substitution option allows participants greater flexibility to tailor their food package for personal preferences. The reduction and eliminations (food package VI) of juice from the food packages also allowed for larger CVVs across all food packages provided to children and women. |
Current rule: Food package IV and VI recipients are prescribed 16 qt of milk per month. Food package V recipients are prescribed 22 qt of milk per month. Food package VII recipients are prescribed 24 qt of milk per month. Three qt of milk can be substituted for 1 lb of cheese, with the maximum amount of cheese being 1 lb for food packages IV, V, and VI and 2 lb for food package VII. Food package VII recipients are also prescribed 1 lb of cheese as a separate food package category. At state agency option, 1 qt of yogurt may be substituted for 1 qt of milk for women and children in food packages III–VII. No more than 1 qt of yogurt is authorized per participant. No more than a total of 4 qt of milk may be substituted for a combination of cheese, yogurt or tofu for children and women in food packages IV–VI. No more than a total of 6 qt of milk may be substituted for a combination of cheese, yogurt or tofu for women in food package VII. Proposed revision: Food package IV-A recipients are prescribed 12 qt of milk per month. Food package IV-B recipients are prescribed 14 qt of milk per month. All women are prescribed 16 qt of milk per month. Cheese is no longer offered as a separate food package item. Children and women can substitute up to 4 qt of milk per month, choosing either to substitute 2 qt of yogurt for 2 qt for milk or to substitute 1 lb of cheese and 1 qt of yogurt for 4 qt of milk. Fully breastfeeding women can choose from a third substitution option of 2 lb of cheese for 6 qt of milk. Only one substitution option can be selected per month. At the discretion of the state agency, yogurt may be prescribed as a range of 30 to 32 oz, to accommodate different container sizes available on the market. (Net cost effect: savings)
| The proposed revisions would reduce the costs of the food packages. This reduction helps offset costs elsewhere in the food packages. | The administrative burden is expected to be short term, as the revision changes quantities, rather than adding new items. It will require training WIC staff and participants of the changes and revised substitution options. Management Information Systems will need to be updated. | The total amount of milk purchased by WIC participants with their food benefit is expected to decrease. The revised quantities and substitution options eliminate participants' need for milk in a quart-sized container. More yogurt may be purchased by WIC participants under the revised substitution options, as 1 and 2 qt substitution options are allowed. The state agency option of a range of yogurt container sizes (30 to 32 oz) may also lead to increased redemption. Stocking requirements are not expected to substantially expand or change. | The proposed revisions provide supplemental quantities of milk across the food packages. The substitution structure eliminates the possibility of a dangling quart and may be more compatible with cultural needs or preferences. |
Current rule: Food packages V and VII recipients are prescribed 1 lb of whole wheat bread or other authorized options. Food package IV recipients are prescribed 2 lb of whole wheat bread or other authorized options. Authorized whole grain options include brown rice, bulgur, oats, whole grain barley, tortillas, and macaroni (pasta). Proposed revision: Food packages IV, V, and VII recipients are prescribed one 16 to 24 oz 100% whole wheat bread or other authorized whole grain option. Allowable whole grain options include brown rice, bulgur, oats, whole grain barley, tortillas, macaroni (pasta), corn masa flour (non-whole grain), cornmeal, teff, and buckwheat. (Net cost effect: savings)
| The proposed revisions are expected to decrease food package costs. The expanded list of whole grain options is available at the discretion of state agencies, within cost-containment parameters. | The expanded list of whole grain options that states can authorize is intended to better meet the cultural and personal preferences of the participants they serve, within cost containment parameters. The expansion of whole grain sizes will require the Management Information Systems to be updated. WIC staff, vendors, and participants will need to be trained on new sizes and options. | The range of whole wheat bread sizes may lead to the elimination of the 16 oz bread size in the market, which was principally created for the WIC population. The proposed revision is likely to lead to stocking requirements that better reflect widely available sizes. Vendors will need to train personnel to identify WIC-eligible breads and grains. | WIC participants will benefit by allowing whole wheat breads that are readily available in the market. The expanded state options for substitutions may allow options that better meet diverse cultural needs and personal preferences. |
Current rule: Food package VII recipients are prescribed 30 oz of canned fish per month. May be packed in water or oil. Pack may include bones or skin. May be regular or lower in sodium content. At the state agency's option, added sauces and flavorings are allowable. Proposed revision: Food packages IV, V-A, and VI recipients are prescribed 10 oz of fish once every 3 months. Food package V-B recipients are prescribed 10 oz of fish every month and food package VII recipients are prescribed 20 oz per month. May be packed in water, but may not be packed in oil. All other specifications remain the same. (Net cost effect: increase)
| Addition of fish across the food packages will increase food packages costs. The additional costs are offset by other changes across food packages. | Implementing the proposed change will increase the short-term administrative burden. Management Information Systems will need to be revised. WIC staff, vendors, and participants will need to be trained on new quantities and rotation pattern for food packages IV, V-A, and VI. The burden is expected to be relatively minor, as all food packages would be authorized the same canned fish. | The proposed revision is expected to increase the amount of water-packed canned fish purchased by WIC participants with their food benefit. The revision may increase minimum stocking requirements for small vendors. Vendors will need to train personnel to identify authorized canned fish products. | Provision of water-packed canned fish provides a high nutrient-density source of nonperishable seafood, and better aligns the food packages with DGA recommendations. |
Current rule: Food packages IV and VI recipients have the option of being prescribed 1 lb dried legumes (or 64 oz of canned legumes) or 16 to 18 oz of peanut butter per month. Food packages V and VII are prescribed 1 lb legumes (or 64 oz of canned legumes) and 16 to 18 oz of peanut butter per month. Proposed revision: Food package IV recipients receive peanut butter, legumes, and canned fish in rotation over 3 months. All women receive legumes and peanut butter once each in a quarter. Both canned and dried legumes must be allowed by all state agencies. (Net cost effect: savings)
| Reduction of the amount of legumes and peanut butter prescribed in food packages IV through VII will result in a cost savings. | States and local agencies will need to educate participants about the legume and peanut butter rotation patterns for children and women. States that do not currently authorize canned legumes will incur a short-term administrative burden of expanding to include the canned option. Management Information Systems will need to be revised. | Sales of legumes and peanut butter to WIC participants using their food instrument will decrease. Market effect is expected to be minimal. | This change brings children's and women's food packages in better alignment with the concept of supplemental and the recommendations of the DGA. Cost savings help offset costs of revisions throughout the food packages. |
Current rule: Children are prescribed an $8 CVV per month. Women are prescribed an $11 CVV per month. Proposed revision: The monthly CVVs for food packages IV, V-A, V-B, VI, and VII are $12, $15, $25, $15, and $35, respectively. (Net cost effect: increase)
| Increasing the CVV across the food packages will increase food package costs. The additional costs are offset by other changes across food packages. | The infrastructure already exists to provide the CVV through the program, which greatly reduces the administrative burden associated with the proposed changes. Management Information Systems will need to be updated. States and local agencies will need to develop ways to communicate the change in the short term, and encourage use of the CVV for vegetables, to align use with the DGA. | Sales of vegetables and fruits will increase through WIC participants using their food benefit. Minimum stocking requirements will slightly increase for vendors that meet the current federal minimum stocking requirement vegetables. Vendors in states that currently only allow fresh fruits may experience additional stocking requirements, as frozen, canned, and/or dried options are authorized. | Increasing the CVV expands the amount of vegetables and fruits participants are able to buy with their food instrument. Provision of a dollar amount, allows participants flexibility and choice to meet cultural needs and personal preferences. Larger CVV values in food packages V-B and VII are intended as incentives to partial (mostly) and full breastfeeding. |
